OF HYPOCRISY, MENHADEN, AND ATLANTIC STRIPED BASS

 

Anyone paying attention to the Atlantic States Marine Fisheries Commission’s Annual Meeting last week knows that it was not a good week for conservation.

The annual catch limit for Atlantic menhaden was reduced by a bit, but by nowhere near as much as a recent stock assessment update suggested was needed.  A day later, multiple members of the Atlantic Striped Bass Management Board admitted that the striped bass stock was headed for serious trouble in the next decade, but took no meaningful action that might help, in any way, to avert that pending crisis.  And although I’m not too familiar with the red drum fishery in the South Atlantic, friends who are have been critical of measures adopted to manage that fishery, too.

I don’t agree with the actions taken with respect to the menhaden limit, nor do I agree with the inaction with respect to striped bass.  At the same time, I understand the arguments underlying the management boards’ decisions in those fisheries, and believe that at least the majority of the Atlantic Menhaden and Atlantic Striped Bass management board were acting in good faith when they cast their votes.

I cannot say the same for some of the organizations that commented on the menhaden and striped bass proposals, comments that saw such organizations speaking out of both sides of their mouths, perhaps trying to convince the public of their good intentions, but making it clear, to anyone that cared to read the comments that they submitted, that they were engaging in hypocrisy of the first order.

A letter addressed to the Chair of the ASMFC’s Atlantic Menhaden Management Board, publicly released by the dubiously-named Coastal Conservation Association just ahead of the Atlantic Menhaden Management Board meeting, argued, in part, that

“Fishing Atlantic menhaden below their [ecosystem reference point fishing mortality] target is necessary to support striped bass rebuilding.  The [ecosystem reference point] framework explicitly links menhaden harvest levels to striped bass population outcomes…By reducing fishing mortality below the [ecosystem reference point fishing mortality] target, additional forage is left in the system, lowering the probability of prey limitation on striped bass growth, survival, and recruitment.  This precautionary strategy also accounts for uncertainty in stock assessments, predator-prey interactions, and environmental variables, thereby increasing the likelihood that striped bass can rebuild to their biomass target, within the mandated time frame under the ASMFC’s rebuilding requirements.”

The letter was signed by the CCA, along with eleven other organizations, including BoatUS, the Marine Retailers Association of the Americas, and the Theodore Roosevelt Conservation Partnership, and anyone reading it could easily believe that all of the signatories were honestly concerned about striped bass conservation, at least until they reached this paragraph, which contains some questionable, and probably intentionally deceiving, claims and might raise some readers’ doubts:

“The ASMFC has two primary levers to support striped bass rebuilding: controlling striped bass fishing mortality and menhaden fishing mortality.   The Atlantic Striped Bass Board has already demonstrated leadership by implementing multiple years of regulatory changes that reduced fishing pressure to a 30 year low, with striped bass fishing mortality now well below the target and threshold.  This means that striped bass fishing mortality is no longer the limiting factor for rebuilding…If the ASMFC also wants to rebuild the striped bass stock, then it needs to manage equally among both species…”

After the Atlantic Menhaden Management Board failed to the 2026 annual catch limit to the level proposed in the letter—a level that reflected a 50% probability of not overfishing, according to the latest stock assessment update—the Coastal Conservation Association put out a press release blasting the management board’s actions, announcing that

“Fisheries Managers Fail to Protect Menhaden, Striped Bass,”

and that

“This week, the Atlantic States Marine Fisheries Commission voted to allow an Atlantic menhaden catch that will not leave enough menhaden in the water for striped bass.  Catch was set at 186,000 [metric tons], when scientists said that a quota of 108,000 [metric tons] was necessary to have a 50% chance of success of rebuilding the striped bass fishery…”

Again, the language is more than a little misleading, and that was probably intentional.  Shortly after that release was sent out, the Coastal Conservation Association’s Maryland chapter issued its own release, using different language to send the same inaccurate message, beginning:

“Revised models indicate the need to cut commercial [menhaden] quota by more than half to rebuild striped bass populations.”

Another organization, the Theodore Roosevelt Conservation Partnership, echoed CCA Maryland’s words in its own release, which also said that

“’Rebuilding the Atlantic striped bass population has always involved more than just regulating striped bass harvest.  It’s also about ensuring that enough of their key food sources, Atlantic menhaden, remains available in the water,’ said Chris Macaluso, director of the Center for Fisheries for the Theodore Roosevelt Conservation Partnership.  ‘The Menhaden Management Board’s decision to adopt only a 20 percent reduction in menhaden harvest, despite the science and input from ASMFC’s own scientists who highlighted the risks, makes it more challenging to achieve striped bass rebuilding by 2029…”

As noted earlier, all of those comments overstate the connection between striped bass rebuilding and cutting menhaden landings.  Striped bass are a generalist predator that, over the course of their lives, feed on everything from alewives to zooplankton.  The most recent benchmark stock assessment informs us that

“Adult striped bass consume a variety of fish (e.g., Brevoortia tyrannus [Atlantic menhaden], Anchoa mitchili [bay anchovy], Mendia spp. [silversides]) and invertebrates (e.g., Callinectes sapidus [blue crab], Cancer irroratus [Atlantic rock crab], Homarus americanus [American lobster]), but the species consumed depends on predator size, time of year, and foraging habitat…[One study] found that that small striped bass (a mean [fork length] of 276 mm [<11 inches]) consumed more invertebrates while large striped bass (a mean [fork length] of 882 mm [<35 inches]) relied more on pelagic fish prey (such as bay anchovies and age-0 clupeids [members of the herring family] in current years than they did in the 1950s…

“…In recent years, particular interest was paid to the role of striped bass as a predator of Atlantic menhaden.  To assess the role of striped bass, ASMFC developed a version of the multispecies [virtual population analysis] with striped bass, bluefish, and weakfish as menhaden predators.  The MSVPA-X predicted that Atlantic Menhaden comprised a moderate proportion of striped bass diet biomass (15-30%) and those consumed consisted largely of age-0 and age-1 Atlantic menhaden.  However, diet studies of large striped bass by [other researchers] suggested a greater role of Atlantic menhaden of all ages in striped bass diets.  Atlantic Menhaden were often dominant prey in studies of striped bass diets in the Chesapeake Bay and the mid-Atlantic region, and were important prey in New England waters.  [references omitted]”

Thus, it’s clear that while menhaden are certainly an important prey for striped bass, saying things like “Fishing Atlantic menhaden below their [ecosystem reference point fishing mortality] target is necessary to support striped bass rebuilding,” ““Revised models indicate the need to cut commercial [menhaden] quota by more than half to rebuild striped bass populations,” and “scientists said that a quota of 108,000 [metric tons] was necessary to have a 50% chance of success of rebuilding the striped bass fishery…” overstate that importance—striped bass have plenty of other forage fish available to make up for a menhaden shortfall—and distort not only reality, but the credibility of those making such claims.

Similarly, such comments demonstrate a deep misunderstanding of the Atlantic menhaden stock assessment that is based on ecosystem reference points (another, single-species stock assessment is also conducted).  In that assessment

“The [ecosystem reference point] target was defined as the maximum [fishing mortality rate] on Atlantic menhaden that would sustain striped bass at their biomass target when striped bass were fished at their [target fishing mortality rate].  The ERP threshold was defined as the maximum [fishing mortality rate] that would keep striped bass at their biomass threshold when striped bass are fished at their [threshold fishing mortality rate].”

However, although the menhaden management plans talk about “ecosystem” reference points, the only species considered in the 2019 Atlantic Menhaden Ecological Reference Point Stock Assessment Report are Atlantic menhaden, striped bass, bluefish, spiny dogfish, and weakfish, with Atlantic herring

“included as a key alternative prey to Atlantic menhaden for the predators identified.”

Other important forage species for striped bass, such as bay anchovy, silversides, and sand eels, were not considered in the assessment, even though they would all be “key alternative prey” for the striped bass.  And that’s perfectly reasonable, because the purpose of that stock assessment was to determine a sustainable population level for menhaden, not to determine the trajectory of the striped bass population based on menhaden availability alone.  To try to use it for the latter purpose, as the various organizations commenting on future menhaden harvest levels did, was a gross misuse of the menhaden assessment.

Still, based just on their comments to the Atlantic Menhaden Management Board, one might excusably come to the conclusion that such organizations truly cared about striped bass rebuilding.  One must read their comments to the Atlantic Striped Bass Management Board, in stark opposition to any reduction in recreational striped bass harvest, to understand that such purported concern was little more than a cloak camouflaging their cupidity and abject hypocrisy.

After all, it’s always easier to manage someone else’s fish.

But if you want to have real credibility as a conservation advocate, you need to be willing to sustainably manage your own fishery, and make whatever necessary sacrifices that may require.

Thus, lowering the menhaden harvest is an easy target for the various fishing tackle, boating, and anglers’ rights organizations.  After all, the organizations’ members don’t fish for menhaden to take home and eat, they don’t intentionally catch and release them, and they don’t manufacture and sell boats and equipment to a menhaden fishery that is almost entirely commercial.  The organizations have nothing to lose if menhaden landings go down.

Thus, they can advocate for menhaden conservation with complete impunity, and use the health of the striped bass stock as an excuse for doing so.

But the easiest way to increase the striped bass population isn’t lowering menhaden landings, but rather lowering landings of the striped bass themselves.  That’s what the draft Addendum III to Amendment 7 to the Interstate Fishery Management Plan for Atlantic Striped Bass proposed to do, by reducing fishing mortality by 12% through a closed season in the ocean fishery and complimentary measures in the Chesapeake Bay.

That proved to be a completely unacceptable option for the same organizations. 

After all, the striped bass fishery is the most important recreational fishery on the East Coast.  Many recreational fishermen catch striped bass to take home and eat, and even for those who choose to return their fish to the water, a closed season, particularly one that did not permit catch-and-release during the closure, would be a hardship.  And when anglers can’t or won’t fish, the tackle industry sells less merchandise, and the boating industry’s sales might be impacted, too.

So, while those industry and anglers’ rights organizations might like to give lip service to the merits of conservation, particularly when they won’t be affected by the relevant conservation measures, when conservation strikes home and might cost them something, it starts looking a lot more like a problem than a worthwhile goal.

Thus, the same Coastal Conservation Association, BoatUS, and National Marine Retailers Association of the Americas that talked about the need to conserve menhaden to rebuild the striped bass, spoke of the need for precautionary management, and warned of the uncertainty in stock assessments when writing to the Atlantic Menhaden Management Board, later joined he Center for Sportfishing Policy, the American Sportfishing Association, and National Marine Manufacturers Association in another letter to the Atlantic Striped Bass Management Board, in which they opposed any reduction in striped bass landings.

Suddenly, taking a precautionary approach to management suddenly seemed like a bad idea, and uncertainty in the data became an excuse for inaction.

It seems that, while causing some level of economic distress to the commercial menhaden fishery is merely an unfortunate but necessary side effect on needed conservation measures, causing any level of economic distress to the fishing tackle and boating industries, in order to conserve striped bass, is unnecessary, completely unacceptable, and must not take place.

The organizations concluded their letter by writing,

“The current striped bass management plan is effective, with fishing mortality well below target levels and protective measures successfully guiding rebuilding efforts toward the 2029 goal.  Draft Addendum III’s proposed 12% reduction, driven by imprecise data and an ineffective approach to managing recreational fisheries, lacks a clear conservation basis and risks unnecessary economic harm…We urge ASMFC to maintain existing seasons to ensure continued progress without imposing undue burdens on anglers.”

It’s a funny thing, but they don’t mention menhaden at all.

In fact, they claim that “the current striped bass management plan is effective,” and “successfully guiding rebuilding efforts toward the 2029 goal,” apparently even though menhaden management isn’t up to their proposed standards.

That’s a lot different from, say, the Coastal Conservation Association’s claim that “a quota of 108,000 [metric tons] was necessary to have a 50% chance of success of rebuilding the striped bass fishery.”

So, what we end up with is a group of organizations willing to use the health of the striped bass stock as an excuse to cut menhaden landings, who then argue that cutting striped bass landings to improve the health of the striped bass stock is a bad idea.

Some might call that being “transactional.”

But hypocrisy is a much better word.